Drone Imaging

Owners: Lucas Denton & Andrew Denton 510 Jarrell Rd. Greenville, Ga 30222 940

-655

-8334 U.S. Department ofTransportation Federal Aviation Administration Oct 30, 2015 Re: Exemption requestpursuant to Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.109; 14 CFR 91.119(C); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(1) and (2); 14 CFR 91.417(a) and (b) Dear Sir or Madam, Pursuant to Section 333 ofthe Federal Aviation Administration (FAA) Modernization and Reform Act of2012 (the “Reform Act”) and 14 CFR Part 11, Lucas Denton, owner ofDrone Imaging (Drone Imaging) which owns and operates an Unmanned Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation ofits UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be establishedby the FAA as requiredby Section 333. Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

- Aerial photography and/or video forpublic and/orprivate use including real estate, architecture, surveying, engineering and other relatedprofessional activities.

- Aerial video and/orphotography forpublic and/orprivate use including television, public events, private events, cinematography andnews gathering.

- Aerial inspection/photography ofresidential/commercial structures under contract with the owners or local government authority.

- Aerial inspection/photography or residential/commercial utility infrastructure including butnot limited to electrical power lines, wind turbines and cell towers.
1

- Aerial video/photography orproviding live video feed to assist with search and rescue operations in cases ofemergency or natural disaster only when the local authorities or government has requested itby contract or donation. Drone Imaging operates one Yuneec Q5004k (4) blade quad copterweighing 3.75 pounds, 1700grams (see attached manual). The UAS has a maximum airspeed of 18 miles per hour and uses a remote controller operating on frequency range of2.400

-2.483 GHZ. The Yuneec Q500 4k is equipped with built

-in ground support technology that allows it to fly utilizing global positioning system (GPS) for stability, tracking, safe flightmode and a return
-to
-home feature in the event ofloss ofremote control signal or critical low battery. All flights start with apre-flight safety check and all flight data are recorded. The Yuneec Q500 4k is equipped with a gimbal mounted camera that sends a live video signal to the controller allowing the person in control (PIC) to monitorreal

-time video. Flight data, speed height, distance, battery level and general aircraft conditions are also displayed during operation. The Yuneec Q500 4kbattery has a flight time of25 minutes and is, therefore, always returned to original takeoffpoint and always flown utilizing visual line ofsight (VLOS). We have been training on the Yuneec Q500 4k for seven months and have become proficient in all aspects offlight and safety ofthis UAS. Our request for exemption would allow us to offer unique aerial photography and videography services to our clientele. UAS Safety Operating ParametersWe will abide by the following additional operating conditions under this

exemption, which ensures a level ofsafety during UAS flight including operating the UAS below 400 feed and within a radius of 1,000 feet from PIC always maintaining VLOS and obtaining permission from the owner/controller ofany vessels, vehicles and structures when operations may be conducted closerthan 500 feet to any such vessels, vehicles or structures. We will conduct a safety assessment ofthe risk ofoperating closer to those objects and determine that it does notpresent an undue hazard. Other safety operating parameters include:

- Operate the UAS for 15

-20 minutes per flight.

- Land UAS prior to the manufacturers recommended minimum level ofbatterypower.

- Operate the UAS during daylight hours only within VLOS.

- Utilize the UAS’ GPS flight safety feature whereby it hovers and then slowly lands if communication with the PIC is lost orbatterybecomes critically low.

- Always obtain all necessarypermissions prior to operation.

- Have procedures in place to abort flights in the event ofsafety breaches orpotential danger.

- Review weatherreports prior to flight and never operate UAS in unsafe conditions, high wind, low clouds or conditions that hinder visibility.

- Only operate in safe environments that are strictly controlled, are away frompower lines,elevated lights, airports and denselypopulated areas.

- Also conduct extensive preflight inspections andprotocols during which safety carries primary importance.
2 The PIC will also have a minimum offive hours logged on this craft and 10 hours minimum flying UAS quad copters under varying conditions and environments and will follow all safetyprotocol ofDrone Imaging as well as guidelines of 14 CFR §61.51(b) having the ability to safely operate the UAS in a manner consistent with the operating documents, including evasive and emergency maneuvers and maintaining appropriate distances frompeople. Specific Exemptions Requested Given the size, weight, speed and limited operating area associated with the UAS, we feel an exemption from 14 CFR Part 21, Subpart H (Airworthiness Certificates) and 14 CFR 91.203(a) and (b) (certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level ofsafety under 14 CFR Part 11 and Section 333 of P.L. 112

-95 (Section 333). We request an exemption from 14 CFR 45.23 Marking ofthe Aircraft because the UAS will not have a cabin, cockpit orpilot station on which to mark certain words orphrases. Further, the two
-inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless ofthis, we can mark the UAS in the largest possible lettering byplacing the word “Experimental” on its fuselage as requiredby 14 CFR 45.29(f) so that anyone will see the markings. We request an exemption from 14 CFR 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in Command. The applicant’s UAS do not carry any pilots orpassengers norproperty. The Risks attendant to the operation ofthe UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR §61. The operation and limitationsin the flight operation manual (FOM) will equate to the safe operations ofthe

UAS. We request an exemption from 14 CFR 91.7(a) which prohibits the operation ofan aircraft without an airworthiness certificate, since there is currently no certificate applicable to our operation, this regulation is inapplicable. We request an exemption from 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)2) and 14 CFR 91.417(a) and (b) Maintenance inspections since they only apply to aircraft with an airworthiness certificate. However, as a safetyprecaution, we will perform apreflight inspection ofthe UAS before each flight as outlined in the attached operating documents. We request an exemption from 14 CFR 91.9(b)(2) which requires an aircraft FOM in the aircraft, however, since there are no pilots orpassengers on board the aircraft, and given its size, this regulation is inapplicable. We believe an equivalent level ofsafety will be achievedby maintaining a safety/flight manual with the UAS ground station. We request an exemption from 14 CFR 91.109 Flight Instruction: Simulated Instrument Flight and Certain Flight Tests. The regulation states that “no person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls. Although the Yuneec Q500 4K is capable ofdual/linked controls, we will be operating with a single remote controller. 3 We request an exemption from 14 CFR 91.119(c) which prescribes safe altitudes for the operation ofcivil aircraft, but allows helicopters to be operated at lower altitudes in certain conditions. We will not operate our UAS above the altitude of400 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus “providing a level ofsafety at least equivalent to orbelow those in relation to minimum safe altitudes.” Given the size, weight and maneuverability and speed ofthe UAS, an equivalent or higher level ofsafety will be achieved. We request an exemption from 14 CFR 91.121 Altimeter Settings, as it is inapplicable since the UAS utilizes electronic GPS with abarometric sensor. We request an exemption from 14 CFR 91.151(a) Fuel Requirements forFlight in visual flight rules (VFR) conditions. The UAS is 100 percent

electric and two lowbattery alerts are issued

–per the operating documents, the UAS will be landed at the first alert. Also, our flights will last only 15

-20 minutes each and the UAS has an automated function, which results in immediate landing when a low battery is detected. The PIC will notbegin a flightunless, considering wind an forecast weather conditions, there is enough power to fly to the firstpoint ofintended landing and, assuming normal cruising speed, land the UAS with 30 percentbatterypower remaining. Summary We will comply with all ofthe following conditions and limitations should this grant ofexemptionbe provided: 1. Operations will be limited to the following aircraft described in the operating documents which is a quad

-rotor aircraft weighing less than seven pounds: Yuneec Q500 4KAircraft System.
2. The UAS will notbe flown at an indicated airspeed exceeding 40 mph.
3. The UAS will be operated at an altitude ofno more than 400 feet AGL, as indicatedby the procedures specified in the operating documents.
4. The UAS will be operated within VLOS ofthe PIC at all times.

5. All operations may utilize a visual observer (VO. The UAS will be operated within the VLOS ofthe VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be designatedbefore the flight and will not transfer his or her designation for the duration ofthe flight. The PIC will ensure that the VO can perform the functions prescribed in the operating documents.6. The operating documents will be accessible during the UAS operations

and made available to the Administratorupon request. Any revisions to the operating documents will be presented to the Administratorupon request.
7. Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the UAS will notbe operated until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station will be included in the preflight inspection. All maintenance and alterations will be properly documents in the aircraft records.
8. Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa flight critical component, will undergo a functional test flight. The PIC who conducts the functional test flightwill make an entry into the aircraft records.

4 9. The pre-flight inspection section in the operating documents will account for all discrepancies, i.e. inoperable components, items or equipment not already covered in the relevant sections ofthe operating documents.
10. We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection and life limit requirements.
11. We will carry out maintenance, inspections and record

-keeping requirements, in accordance with the operating documents. Maintenance, inspection and alterations will be noted in the aircraft records, including total flighthours, description ofwork accomplishedand the signature ofthe authorizedperson returning the UAS to service.

12. Each UAS operated will comply with all manufacturer Safety Bulletins.
13. An authorizedperson will make an entry in the aircraft record ofthe corrective action taken against discrepancies discoveredbetween inspections.
14. The PIC will also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on.
15. Prior to operations conducted for the purpose ofaerial videography/cinematography and augmenting real estate listing videos (or similar operations), the PIC will have accumulated and logged, in a manner consistentwith 14 CFR 61.51(b), a minimum offive hours as an UAS pilot operating the make and model ofthe UAS to be used in operations.
16. The PIC will not operate the UAS for the purpose ofaerial videography/cinematography and augmenting real estate listing videos (or similar operations), unless the PIC has demonstrated and logged in a manner consistentwith 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent with the operating documents, including evasive and emergency maneuvers and maintaining appropriate distances frompeople, vessels, vehicles and structures.
17. UAS operations will notbe conducted during night hours, as defined in 14 CFR 1.1 All operations will be conductedunder visual meteorological conditions (VMC).18. The UAS will not operate within five nautical miles ofan airport

reference point as denoted on a current FAA

-published aeronautical chart.
19. The UAS will notbe operated less than 500 feetbelow or less than 2,000 feet horizontally from a cloud or when visibility is less than three statute miles from the PIC.
20. Ifa UAS loses communications or loses its GPS signal, it will return to apredetermined location within the planned operating area and land or be recovered in accordance with the operating documents.
21. The PIC will abort a flight in the event ofunpredicted obstacles or emergencies in accordance with the operating documents.
22. The PIC will notbegin a flightunless, considering wind and forecast weather conditions, there is enoughpower to fly at a normal cruising speed to the intended landing point and land the UAS with 30 percent batterypower remaining.

23. Before conducting operations, the radio frequency spectrumused for operation and control ofthe UAS will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.
24. The documents required under 14 CFR 91.9 and 14 CFR 91.203 would be available to the PIC at the Ground Control Station ofthe UAS at any time the UAS is operating. These documents will be made available to the Administrator or any law enforcement official upon request.
525. The UAS will remain clear and yield the right ofway to all manned

aviation operations and activities at all times.
26. The UAS will notbe operatedby the PIC from any moving device or vehicle.
27. The UAS will notbe operated over congested or denselypopulated areas unless contracted out to do events.
28. Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles and structures unless:

a. Barriers or structures are present that sufficientlyprotect nonparticipating persons from the UAS and/or debris in the event ofan accident. We will ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UAS, flight operations must cease immediately.
b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has grantedpermission and the PIC has made a safety assessment of the risk ofoperating closer to those objects and determined that it does notpresent an undue hazard.

c. Operations near to the PIC, VO, operator trainees or essential persons do notpresent an undue hazard to those persons per 14 CFR 91.119(a)

.29. All operations will be conducted overprivate or controlled

-access

property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.
30. Any incident, accident or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as definedby the applicable certificate ofauthorization (COA) will be reported to the FAA’s UAS Integration Office (AFS

-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB website: www.ntsb.gov

. On behalfofDrone Imaging, I would like to thank you for your consideration in granting this exemption. Signed, Lucas Denton Drone Imaging